Assessment time-limit extension requires valid reasons and extraordinary circumstances; a bare need for more time is insufficient.

The power to extend the assessment period under section 42 read with rule 37A must rest on valid grounds supported by reasons showing extraordinary circumstances or supervening causes beyond the assessing authority's default. A mere assertion that the inquiry or assessment is unlikely to be completed within the prescribed time is insufficient to justify extension. On that basis, the extension order was held unsustainable and was quashed.

---

---

Issues: Whether the order extending the period of limitation for completing assessment was valid under section 42 read with rule 37A of the Gujarat Sales Tax Act.

Analysis: The power to extend or stay assessment time-limit under the relevant rule can be exercised only on valid grounds supported by reasons showing extraordinary circumstances or supervening reasons beyond the assessing authority's default. A bare statement that more time is needed because the inquiry or assessment is not likely to be completed within the prescribed time is not a sufficient foundation for extension.

Conclusion: The extension order was unsustainable and was quashed.

---